- 6 -
1986, he received unreported cash income from the two
businesses that he owned and that these cash receipts
were unreported in the corporate books.
(d) On that same date, petitioner Ferdinand
DeCaprio allocuted, under penalty of perjury or false
statement, that the additional unreported income that
he received was as follows: $66,000 during the taxable
year 1983; $16,798 during the taxable year 1984;
$19,835 during the taxable year 1985; * * *
(e) On that same date, petitioner Ferdinand
DeCaprio allocuted, under penalty of perjury or false
statement, that he used the unreported cash income to
pay for his personal expenses.
(f) On that same date, petitioner Ferdinand
DeCaprio allocuted, under penalty of perjury or false
statement, that he knew it was illegal to not report on
his income tax return the additional cash income listed
in subparagraph (d) above.
(g) On that same date, petitioner Ferdinand
DeCaprio allocuted, under penalty of perjury or false
statement, that the medication he was using at that
time did not affect his ability to think.
(h) [P]etitioner Ferdinand DeCaprio's fraud-
ulent omission of specific items of income on his
income tax returns filed for the taxable years 1983,
1984, 1985 * * *, is a part of a * * * pattern of
intent to evade taxes.
(i) Petitioner Ferdinand DeCaprio under-
stated his taxable income on his income tax returns for
the taxable years 1983, 1984, 1985 * * *, in the
amounts of $66,000, $16,798, $19,835, * * *, respec-
tively.
(j) Petitioner Ferdinand DeCaprio under-
stated his income tax liabilities on his income tax
returns for the taxable years 1983, 1984, 1985 * * *,
in the amounts of $22,380, $7,474, $9,587, * * *,
respectively.
(k) Petitioner Ferdinand DeCaprio fraudu-
lently, and with intent to evade tax, omitted from his
income tax returns for the taxable years 1983, 1984,
1985 * * * income in the amounts of $66,000, $16,798,
$19,835, * * *, respectively.
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